HomeMy Public PortalAboutPRR 14-12891269
RECEIVED 08/00/2014 13:51 5613946102 5EV
0810812014 14:12 Commerce Group P.0021003
RECORDS REQUEST (the "Request')
Date ot'Request: 8/8/2014
Requestor's Request ID #: 133
REQUESTEE: Custodian of Records - Sweetapple, Brooker, Varkas, P.L.
REQUESTOR: Asset Enhancement, Inc.
REQUESTOR'S CONTACT INFORMATION: E -Mail: records @commerce- gmup.com
Fax: 954- 360 -0807; Address: 1280 West Newport Center Drive, Deerfield Beach, FL 33442
REQUEST:
Please provide all Public Records confirming the language Inserted in the fast
sentence of paragraph 18 of the Defendant's Motion For Sanctions Against
Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C.,
Jonathan '[sic] And William Ring, Esquire, which was filed by ttorney Sweetapple.
ADDITIONAL INFORMATION REGARDING REQUEST:
THIS REQUEST IS MADE PURSUANT TO PUBLIC RECORDS ACT,
CHAPTER 119 OF THE FLORIDA STATUTES AND IS ALSO REQUESTED UNDER THE
COMMON LAW RIGHT TO KNOW, THE COMMON LAW RIGHT OF ACCESS; AND
ANY STATUTORY RIGHT TO KNOW (INCLUDING, WITHOUT LIMITATION, ANY
STATUTORY RIGHT OF ACCESS, AS APPLICABLE). THIS REQUEST IS ALSO MADE
PURSUANT TO THE RIGHTS OF THE REQUESTOR PROVIDED IN THE FLORIDA
CONSTITUTION.
IT 19 REOUESTED THAT THIS RECORDS REOUEST BE FULFILLED IN ELECTRONIC
FORM. IF NOT AVAILABLE IN ELECTRONIC FORM, IT IS REO IFaTED THAT THIS
RECORDS REQUEST BE FULFILL 7 PAPER. NOTE: IN ES NLESS
IM OSSIBLE THE COPIES H LD BE TWO SIDED AND H ULD BE BILLED IN
ACCORDANCE WITH Section 119.07(4) (a) (2)
A. LLLELECTRONIC COPIES ARE REOLiF' -cTED TO BE Cr+'NT BY E MA,ii DELIVERY.
PLEASE PROVIDE THE APPROXIMATE COSTS (IF ANY) TO FULFILL THIS PUBLIC
RECORDS REQUEST IN ADVANCE.
It will be required that the Requester approve of any casts, asserted by the Agency (as defined in
Florida Statute, Chapter 119.01 (Definitions)), In advance of any costs imposed to the Requester by
the Agency.
I:MPJFRR
04.22.13 FORM
RECEIVED 08/08/2014 13:51 5613946102 SBV
08108=14 14:12 Commerce Group MOS5436=7 P.0031003
Martin E. O'Boyle v. Town of oult5tresm
CASE NO. 502Ql4CA004474xxxX v1BAG (PALM BEAM COUNTY)
undertaken to pressure and intimidate defense counsel into not pursuing the issue of whether the
O'Boyle Law Firm is a bona fide Interstate Law Fhm .
I5. The issue of whether the O'Boyle Law Firm Is a bona fide Interstate Law Finn is one that
should be resolved according to law. It should not be the subject of hauwameot, intimidation and air
raids by opposing counsel and their client
16. The misconduct is unprofbasional, unethical and it constitutes an egregious example of
litigation abuse. These tactics go beyond zealous representation and are designed to interfere with
defense counsels' ethical obligation to their client. Such conduct undermines society's commitment
to the resolution of disputes in courts of law, rather than in the streets or in the sky.
17. While citizens e'joy the constitutional right of free speech, that protection is afforded to
truthful speech, and while attorneys must zealously represent their client's interests, they are also
Officers of the court, and are prohibited fmm disparaging witnesses and Attomeys, or otherwise
undermining the administration of justice.
I8. It Is well settled that the trial court has inherent jurisdiction to sanction parties and their
counsel for litigation abuse. In this instance, plaintiff and his counsel have sought to cease any
litigation or determination of the bona fides of the O'Boyle Law Firm by threatening and instituting
reprisals against counsel, their client and families,
19, While O'Boyle has the right to continue to make a spectacle of himself, he, with the assistance
Of counsel, cannot impugn, malign and attempt to extort opposing parties or their counsel as part of
the litigation process.
20. Abusive conduct is not a novelty for O'Boyle, who has left a historic trail of abusive litigation.
5
LAW OMM OFSwIIrAPEA BROMM& VAarne, F.L.
20 SZ3 31Ma61, BOCARATOKRI MA33432.3911
TOWN OF GULF STREAM
PALM BEACH COUNTY, FLORIDA
Delivered via e-mail
November 4, 2014
Asset Enhancement, Inc. [mail to: records @commerce- group.com]
Re: GS #1289 (133), #1295 (123)
Please provide all Public Records confirming the language inserted in the last sentence of
paragraph 18 of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle,
Counsel of Record, The O'Boyle Law Firm, P. C., Jonathan O'[sicj And William Ring, Esquire,
which was filed by Attorney Sweetapple.
Please provide all Public Records which confirm Attorney Sweetapple's statement in the first
sentence of m(mbered paragraph 14 of the Defendant's Motion For Sanctions Against Plaintiff,
Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P. C., Jonathan O'[sic] And
William Ring, Esquire, which was filed by Attorney Sweetapple.
Dear Asset Enhancement, Inc. [mail to: recordsaa commerce- eroun.coml,
This letter is in response to the public records you have requested which we received August 8,
2014. Your original requests can be found at the following link http://www2.gulf-
stream.org/WebLink8/0/doc/20082/Pagel.asi)x and httv://www2.eulf-
stream.ore/WebLink8 /0 /doc /20088/Paeel .asox.
Be advised that no such records exist.
We consider this matter closed.
Sincerely,
Town Clerk
Custodian of the Records